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Developments in Transfer Pricing: From Both Sides Of The Fence

Published on 01 Oct 2009 | Took place at RACV Club, Melbourne , VIC

This event was part of the Corporate Tax Club Series.

The ATO has signalled transfer pricing as a continuing area of focus, with particular controversy now attaching to the breadth of its transfer pricing powers as well as their source, treaty or statute, and the implications of both issues for the methodologies it can employ and the extent to which it can recharacterise transactions.

This event addressed the utility of profit based methods in the Australian environment after the decision in Roche Products, the approach to financing transactions in light of recent pronouncements by the Commissioner and other recent TP developments from both a taxpayer and an ATO perspective.

Individual sessions

Developments in transfer pricing - Practitioner’s perspective

Author(s):  Jane ROLFE

This presentation covers:

  • transactional net margin and comparable uncontrolled price methodologies - what is the current position?
  • financing transactions (loans and guarantees and the thin cap interface)
  • the role of treaties - independent power to assess?
  • the new International Dealings Schedule.
Materials from this session: